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Climate Challenge Participation Letter

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CLIMATE CHALLENGE PARTICIPATION ACCORD
BETWEEN
TEXAS UTILITIES ELECTRIC COMPANY
AND THE
U. S. DEPARTMENT OF ENERGY


This Participation Accord describes the commitments that Texas Utilities Electric Company (TU Electric or the Company) and the U.S. Department of Energy (DOE) have made to participate in the Climate Challenge Program in pursuit of the President's goals for reducing greenhouse gas emissions. The Climate Challenge Program is a joint, voluntary effort of DOE and the electric utility industry to reduce, avoid or sequester greenhouse gas emissions. The framework of the Climate Challenge Program was established in the Climate Challenge Program Memorandum of Understanding and exhibits thereto dated April 20, 1994 (the Climate Challenge Program MOU) (see Attachment A to this Participation Accord).

I. TU Electric Commitments

A.

    Consistent with paragraphs II.B.1.a and II.B.1.f of the Climate Challenge Program MOU, TU Electric will participate in two Industry Initiative Programs (detailed descriptions of these programs are provided in Exhibit A of the MOU), and has undertaken or will undertake the following specific projects to reduce, avoid, or sequester greenhouse gas emissions.

    1.

      TU Electric joined the National Earth Comfort Program on October 4, 1994. The specifics of this Industry Initiative Program are described in Exhibit A of the MOU, which is attached as part of this accord. TU Electric has made a commitment to support this program financially for six years at an initial annual level of funding of $50,000. In addition to financial support, the Company is participating on industry leadership committees responsible for directing or advising the Geothermal Heat Pump Consortium.

      Estimates of the annual quantities of greenhouse gases reduced, avoided, or sequestered by the Company as a result of this initiative are yet to be determined.

    2.
      TU Electric joined the Utility Forest Carbon Management Program in August 1994. The specifics of this Industry Initiative Program are described in Exhibit A of the MOU, which is attached as part of this accord. TU Electric has made a commitment to support this program financially at a level of $5,000 per year, and is participating on the industry committee responsible for directing the efforts of this program.

      Estimates of the annual quantities of greenhouse gases reduced, avoided, or sequestered by the Company as a result of this initiative are yet to be determined.

    3.
      Fossil-fueled generating station heat rate improvement projects. Since January 1, 1991, the Company has implemented or will implement over thirty major projects to improve the heat rate at 14 of its fossil-fueled generating plants, including DeCordova, Sandow, Big Brown, Lake Hubbard, Handley, Graham, North Lake, Mountain Creek, Eagle Mountain, Permian Basin, Monticello, Martin Lake, Tradinghouse and Valley steam electric stations. Each of these projects will reduce annual greenhouse gas emissions by a minimum of 1,000 tons of CO2.

      The Company estimates that this effort, when fully implemented, will result in the annual reduction of tons of CO2 as listed in Table 1.

    4.
      Demand-side management programs. The Company has developed 8 DSM solicitation projects and 19 DSM rebate programs and submitted these programs to the Texas Public Utility Commission for approval on October 25, 1994. These projects include solicitations from CES/Way International, Inc., Encon Systems, Inc., Entergy Systems and Service, Inc., Highland Energy Group, Inc., MC2 Energy Management, Princeton Development Corporation, TAMAL Energy Services Corporation and the Tarrant County Water District. Examples of the rebate programs include several residential "energy-wise" or "e-Wise" programs, such as e-Wise New Single Family home program, e-Wise New Multifamily home program, e-Wise Residential Lighting program, e-Wise Thermal Cool Storage, and 6 e-Wise Commercial and Industrial programs (chillers, HVAC, electrical, lighting, thermal insulation, and motors).

      Pending future Texas Public Utility Commission approval, TU Electric will implement these programs which collectively would total over 620 MW of avoided future fossil-fueled electric generation.

      The Company estimates that these efforts, if fully implemented, will result in the annual reduction of tons of CO2 as listed in Table 1.

    5.
      Renewable energy development projects. Since January 1, 1991, the Company has put in place three wind turbines and several photovoltaic applications. In addition, the Company will develop a 40-MW wind-energy project in West Texas, pending approval by the Public Utility Commission of Texas. The Company's current Integrated Resource Plan also calls for the installation of an additional 100 MW of wind-energy by the year 2000.

      The Company estimates that its renewable energy development projects, if approved by the Utility Commission, will result in the annual reduction of the tons of CO2 as listed in Table 1.

    6.
      Operation of nuclear generation units. Unit 2 of TU Electric's nuclear generating station, the Comanche Peak Steam Electric Station, began commercial operation after January 1, 1991. TU Electric will continue to operate this 1,150 MW unit as baseload capacity (as well as the 1,150 MW Comanche Peak Unit 1 which completed its first full calendar year of commercial operation in 1991) on the TU Electric system, resulting in the generation of virtually no greenhouse gases. In addition, since January 1991, the Company has improved the availability of the two Comanche Peak units, chiefly by extension of refueling schedules and shortening of the refueling outage durations. These actions avoid generation of greenhouse gases.

      The Company estimates that its nuclear program will result in an annual reduction of tons of CO2 as listed in Table 1.

    7.
      Natural gas-fueled electric generation projects. TU Electric will add natural gas-fueled combined-cycle combustion turbines as new generating units rather than coal-fueled units that had previously been planned to meet energy needs through the year 2000. With the exception of the Comanche Peak nuclear units and three wind turbines, all new generation capacity on the TU System over the past several years has been fueled by natural gas. In addition, most of the power purchased to meet load requirements over the last few years has been from natural gas-fired cogeneration or other gas-fired facilities.

      Installation of the new gas-fueled generating units included in the Company's Integrated Resource Plan requires approval of the Texas Public Utility Commission. Estimates of the annual quantities of greenhouse gases avoided as a result of the Company's plans are listed in Table 1.

    8.
      Recycling projects and activities. The Company plans to increase its recycling activities, including the sale of combustion byproducts, in future years. In most cases the use of recycled materials instead of virgin materials in production processes, such as the use of coal ash in the manufacture of cement, requires less energy which will result in the avoidance of greenhouse gas emissions.

      Estimates of the annual quantities of greenhouse gases reduced, avoided, or sequestered as a result of recycling projects and activities are not yet available.

    9.
      Increase reforestation in land reclamation program. The Company will double the number of acres planted in trees in its mine reclamation programs above the number of acres historically planted beginning in 1995. The resulting increase in the number of trees planted will depend upon the species selected and local site characteristics. Historically, the Company has planted around 500,000 trees annually in its mine reclamation program, and this commitment will increase the number of trees planted. Carbon will be sequestered over the life of these forest stands. Additionally, the Company will increase carbon sequestration in its premining vegetation removal program by increasing the use of this vegetation for wood pulp, mulch, lumber products, and other uses.

      The Company estimates that its efforts in this area will result in an annual reduction of tons of CO2 as listed in Table 1.

    10.
      Texas Reforestation Foundation program. The Company has signed an agreement with the Texas Reforestation Foundation to fund the reforestation of up to 300 acres per years of small, previously logged acreages in the Company's service territory. This carbon sequestering activity begins in early 1995 and is currently committed through the year 2000.

      The Company estimates that tons of CO2 will be sequestered on an annual basis as a consequence of this program as listed in Table 1.

    11.
      Vehicle use activities. The Company has reduced the number of vehicle miles driven to accomplish certain work efforts, such as meter reading, and maintenance and repair of transmission and distribution facilities. The Company will continue to look for opportunities to improve worker efficiency, such as consolidating or otherwise modifying its operations to reduce the travel times and miles driven by its work crews and other employees. These activities also reduce vehicle emissions, including emissions of greenhouse gases.

      Estimates of the annual quantities of greenhouse gases reduced, avoided, or sequestered as a result of these activities are not yet available.

B.

    TU Electric will report annually on activities and achievements under the Climate Challenge Program. Results achieved during each year shall be reported in a clear and understandable manner that is consistent with the guidelines adopted pursuant to subsection 1605(b) Energy Policy Act and with Exhibit B, Supplemental Guidance on Commitment Definition and Reporting, of the Climate Challenge Program MOU. The first such report may include a description of the activities and achievements of TU Electric prior to its becoming a participant in the Program, expressed on an annual basis to the extent possible.

C.
    TU Electric will confer with DOE on or before February 15, 1997, to evaluate jointly the progress of the Company in achieving its Climate Challenge Program goals and to discuss possible adjustments to its voluntary commitments.

D.
    TU Electric has received written confirmation that The Nature Conservancy has agreed to serve in an advisory capacity on the Company's Climate Challenge Program (see Attachment B). TU Electric will meet with The Nature Conservancy on an annual basis to review, assess, and receive input on the Company's activities and achievements under the Climate Challenge Program.

E.
    The Climate Challenge Program representative for TU Electric will be:

        Mr. Richard L. White
        Vice President, Environmental Services
        Texas Utilities Electric Company
        1601 Bryan Street
        Dallas, Texas 75201

    TU Electric agrees to notify DOE prior to or, in any event, no later than 30 days after any change in the contact.

II. DOE Commitments

    A.
      DOE's commitments to TU Electric are those set out in section III of the Climate Challenge Program MOU, which are hereby incorporated in this Participation Accord by reference.

    B.
      will consider TU Electric requests to intervene in regulatory proceedings of federal, state and local commissions and boards on issues pertinent to the Climate Challenge Program. Before DOE intervenes in regulatory and other proceedings pertaining to TU Electric for purposes of addressing Climate Challenge Program issues, it will provide notice to TU Electric.

    C.
      DOE will provide an annual report to TU Electric describing the actions that it has taken to fulfill its commitments under section III and Exhibit C of the Climate Challenge Program MOU and the results of those actions.

    D.
      The Climate Challenge Program representative for DOE, who will serve as liaison to TU Electric, will be:

          Dr. Allan Hoffman
          U.S. Department of Energy
          Room 6B-128 (EE-10)
          1000 Independence Avenue SW
          Washington, D.C. 20585
          Phone: (202) 586-1786

      DOE agrees to notify TU Electric prior to or, in any event, no later than 30 days after any change in liaison responsibilities or personnel.

III. General Provisions

    A.
      Use of DOE-developed materials by TU Electric will be governed by the provisions of section IV of the Climate Challenge MOU, which are hereby incorporated in this Participation Accord by reference.

    B.
      In addition to the foregoing provisions, DOE and TU Electric agree to act in accordance with the principles set out in section I of the Climate Challenge Program MOU and the general provisions set out in subsections V.A-V.D, V.F and V.G of the Climate Challenge Program MOU, which are hereby incorporated by reference.

    C.
      Either party may withdraw from this Participation Accord or any of its activities under the Climate Challenge Program without penalty and without being subject to remedies at law or equity.

(Original signed by)
______________________________

Texas Utilities Electric Company

(Original signed by)
______________________________

Secretary of Energy
U.S. Department of Energy

Attachments:

Table 1 -- Estimates of Greenhouse Gases Reduced, Avoided, or Sequestered

Attachment A -- Climate Challenge Program MOU and exhibits

Attachment B -- Letter from The Nature Conservancy


TABLE 1

ESTIMATES OF GREENHOUSE GASES REDUCED,
AVOIDED, OR SEQUESTERED


                    Activity                      Tons of Greenhouse Gases Reduced,       

                                                      Avoided or Sequestered 

                                                  (Quantities expressed as tons of 

                                                  CO2 equivalent in the year 2000)

___________________________________________________________________________________ 



1.  National Earth Comfort Program                                  *                       

2.  Utility Forest Carbon Management Program                        *                        

3.  Fossil-fueled generating station heat                         431,745                   

    rate improvement projects                                                          

4.  Demand-side management programs                             1,148,011                    

5.  Renewable energy development projects                         223,440                    

6.  Operation of nuclear generation units                      14,414,949                   

7.  Natural gas-fueled electric generation                      2,296,496                            

    projects                                                                                     

8.  Recycling projects and activities                               *                        

9.  Increase reforestation in land                                 29,182                    

    reclamation program                                                                 

10. Texas Reforestation Foundation program                         18,277                     

11. Vehicle use activities                                          *                   

                                                             ____________

            TOTAL                                              18,562,100                   



* To be determined



Please send comments to:
Lawrence.Mansueti@hq.doe.gov